Through complex equity structure design, corporate income is arranged in jurisdictions with loose taxation, so as to minimize the tax burden on a global scale, which usually involves international tax planning, the design of the structure of multinational companies, and the legal use of tax incentives in different countries and regions. Policies. The following are some common strategies and methods： ### 1. **Establishment of a holding company** -**Intermediate holding company**: Set up intermediate holding companies in low-tax or tax-exempt countries or regions (such as the Cayman Islands, Bermuda, Ireland, etc.) to transfer income to these companies through an equity structure. These regions usually do not impose corporate income tax on corporate income, or the tax rate is extremely low. -**Regional headquarters**: Set up regional headquarters in certain tax-preferential areas to concentrate profits in these areas through transfer pricing, royalties, etc. ### 2. **Transfer pricing strategy** -**Internal transactions**: Through transactions between companies within the group (such as goods, services, intellectual property rights, etc.), profits are transferred from high-tax countries to low-tax countries. For example, royalties are collected by licensing intellectual property rights to subsidiaries in low-tax countries. -**Cost sharing agreement**: Through the cost sharing agreement, R&D expenses, marketing expenses, etc. are distributed to subsidiaries in low-tax countries, thereby reducing taxable profits in high-tax countries. ### 3. **Use of tax treaties** -**Double taxation agreements**: Through the establishment of holding companies in different countries, double taxation agreements are used to avoid or reduce the tax burden in multiple countries. For example, through the establishment of holding companies in countries such as the Netherlands or Luxembourg, the extensive network of tax treaties in these countries can be used to reduce withholding taxes and income taxes. -**Abuse of tax treaties**: Abuse of tax treaties by setting up “shell companies” or "conduit companies" to transfer income to low-tax countries. Although this behavior may be challenged by anti-avoidance rules, it may still be effective in some cases. ### 4. **Capital weakening** -**Debt financing**: By setting up subsidiaries in high-tax countries and increasing interest expenditures through debt financing (such as loans), taxable profits are reduced. Interest payments can usually be deducted before tax, and the lender is usually located in a low-tax country, thereby transferring profits to a low-tax country. ### 5. **Intellectual property arrangements** -**Intellectual property holding**: Subsidiaries that hold intellectual property rights (such as patents, trademarks, copyrights, etc.) in low-tax countries transfer profits to these countries through royalties. -**Intellectual property research and development**: Set up R&D centers in low-tax countries to concentrate profits in these countries through R&D cost sharing and intellectual property holdings. ### 6. **Offshore company** -**Offshore company**: Set up a company in an offshore financial center (such as the British Virgin Islands, the Cayman Islands, etc.) to hold assets or conduct transactions through an offshore company, thereby retaining income in low-tax or tax-exempt jurisdictions. ### 7. **Hybrid entities and hybrid tools** -**Mixed entities**: Use the different regulations of different countries on the classification of entities to treat certain entities as transparent entities (such as partnerships) in some countries and opaque entities (such as companies) in others, thereby avoiding or reducing the tax burden. -**Hybrid instruments**: Use hybrid financial instruments (such as convertible bonds, preferred stocks, etc.) to minimize the tax burden through different tax treatments of financial instruments in different countries. ### 8. **Response to the Global minimum tax burden rule (BEPS)** -**BEPS Action Plan**: The “Base Erosion and Profit Shifting” (BEPS) Action Plan launched by the Organization for Economic Cooperation and Development (OECD) aims to combat tax avoidance by multinational companies. Companies need to pay close attention to changes in the rules of BEPS to ensure the compliance of tax planning. -**Global minimum tax**: With the introduction of global minimum tax burden rules (such as the 15% global minimum corporate tax), companies need to reassess their tax planning strategies to ensure that the minimum tax burden requirements are met on a global scale. ### 9. **Tax resident status management** -**Tax resident status**: Through reasonable arrangement of the tax resident status of the enterprise, choose to become a tax resident in a low-tax country or region, thereby reducing the global tax burden. For example, by setting up management and control centers in certain countries, the status of tax residents has been changed. ### 10. **Avoidance of anti-tax avoidance rules** -**Anti-tax avoidance rules**: Many countries have introduced anti-tax avoidance rules (such as CFC rules, transfer pricing rules, etc.). Companies need to ensure that their tax planning strategies do not violate these rules and avoid tax risks. ### 11. **Compliance and risk management** -**Tax compliance**: Although tax planning can legally reduce the tax burden, companies must ensure that their tax planning strategies comply with the laws and regulations of various countries to avoid tax risks. -**Tax audit and dispute resolution**: Enterprises should be prepared to deal with tax audits and disputes to ensure that their tax planning strategies can withstand the review of the tax authorities. ### 12. **Professional consultation** -**Tax consultants**: Since international tax planning involves complex legal and tax issues, companies should seek the help of professional tax consultants and lawyers to ensure the legitimacy and effectiveness of their tax planning strategies. ### Conclusion Through the design of a complex equity structure, companies can minimize their tax burden on a global scale, but this process needs to be handled carefully to ensure compliance with national tax regulations.